Kirk A. Keegan, Jr. - Page 9

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            by the taxpayer by her signature on the assent form, was a clear                          
            and concise agreement, in written form, delineating the terms                             
            under which the husband would support the taxpayer.  The payor-                           
            husband's signature on the letter was not necessary for the                               
            agreement to be valid, as his attorney acted as his agent and the                         
            husband in fact carried out the terms of the agreement.                                   
                  In contrast to the letter in Azenaro v. Commissioner, supra,                        
            the language of the March 30, 1992, letter is unequivocally that                          
            of a proposal or offer to negotiate.  ("If this arrangement is                            
            acceptable * * *.")  The March 30, 1992, letter was not signed by                         
            Mrs. Keegan, nor was any other writing acceding to its terms                              
            executed on her behalf.  See Estate of Hill v. Commissioner,                              
            supra at 856-857; Harlow v. Commissioner, T.C. Memo. 1984-393 ("A                         
            unilateral written statement by a party stating that he is                                
            willing to pay his spouse certain sums for her support clearly                            
            does not meet the statutory requirement of a written separation                           
                  Petitioner next cites Jefferson v. Commissioner, supra, in                          
            support of his contention that "though the letter itself                                  
            constituted a proposal, its acceptance made it an enforceable                             
            agreement and a 'written instrument' within the meaning of                                
            section 71."  However, Jefferson v. Commissioner, supra, is                               
            distinguishable from the facts of this case.  In Jefferson v.                             

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